G.R. No. 254564 /G.R. No. 254974/A.M. No. 21-07-16-SC/A.M. No. 18-03-16-SC, July 26, 2022
PEOPLE OF THE PHILIPPINES, PETITIONER, VS. ERICK MONTIERRO Y VENTOCILLA, RESPONDENT. [G.R. No. 254974] CYPHER BALDADERA Y PELAGIO, PETITIONER, VS. PEOPLE OF THE PHILIPPINES, RESPONDENT.

FACTS

These consolidated cases involve two separate prosecutions for violation of Section 5 (illegal sale) of Republic Act No. 9165 . Respondent Erick Montierro was charged for selling 0.721 grams of shabu, while petitioner Cypher Baldadera was charged for selling 0.048 grams. During the pendency of their cases, the Supreme Court, in Estipona, Jr. v. Lobrigo, declared the statutory prohibition against plea bargaining in drug cases unconstitutional, affirming the Court’s exclusive rule-making power. Consequently, the Court promulgated A.M. No. 18-03-16-SC (the Plea Bargaining Framework), which allowed an accused charged under Section 5 to plea bargain to a violation of Section 12 (possession of paraphernalia) if the shabu involved is between 0.01 to 0.99 grams.
Both accused, whose cases fell within this threshold, filed motions to plea bargain pursuant to the Framework. The prosecution, however, opposed these motions, citing conflicting Department of Justice (DOJ) circulars that either prohibited plea bargaining for Section 5 entirely or prescribed a plea bargain to Section 11 (possession) instead. The trial courts granted the accused’s motions, but the prosecution successfully petitioned the Court of Appeals (CA) to reverse these orders. The CA ruled that the prosecution’s consent is indispensable to a valid plea bargain. The matter was elevated to the Supreme Court, alongside administrative letters from judges seeking clarification on the plea bargaining guidelines.

ISSUE

The core issue is whether an accused charged with illegal sale of dangerous drugs under Section 5 of R.A. No. 9165 , where the quantity is 0.01 to 0.99 grams, can be allowed to plea bargain to a lesser offense under the Court’s Plea Bargaining Framework over the objection of the public prosecutor.

RULING

The Supreme Court ruled in the affirmative, granting the petitions and reinstating the trial courts’ orders allowing the plea bargains. The Court held that its Plea Bargaining Framework, issued pursuant to its constitutional rule-making authority, is binding on all courts and must prevail over any conflicting issuances from the executive department, such as the DOJ circulars. The Framework was established to address procedural matters and ensure the efficient administration of justice, which falls squarely within the Supreme Court’s exclusive domain.
The Court clarified that while the prosecution’s agreement is generally required for a plea bargain, this rule is not absolute. A judge may override the prosecution’s disapproval if it is based solely on a policy that contravenes the Court’s own rules. The DOJ’s circulars, which sought to prohibit or restrict plea bargaining contrary to the Framework, constituted an invalid encroachment on judicial power. Therefore, the prosecution’s objection, grounded solely on these invalid circulars, was without legal basis. The trial courts correctly applied the binding Framework, and their discretion to approve the plea bargains was a valid exercise of judicial authority aimed at decongesting dockets and expediting case disposition, provided the accused’s guilt for the lesser offense is established and the plea is made voluntarily.